28 June 2019 Andrew Harrison Commerce Commission
[email protected] BY EMAIL Submission to the Commerce Commission: Mobile Market Study – Preliminary Findings Introduction 1. Nova Energy Limited (Nova) welcomes the opportunity to provide a submission to the Commerce Commission in relation to its Mobile Market Study – Preliminary Findings. 2. By way of background, Nova is a wholly owned subsidiary of The Todd Corporation, which has been one of New Zealand’s leading energy explorers and producers for around 60 years. Todd Generation Limited, also a wholly owned subsidiary of The Todd Corporation, holds an interest in approximately 170 megawatts of installed power generation capacity. Nova is a supplier of electricity and natural gas to wholesale, retail and industrial markets. In 2018 Nova entered the telecommunications market and currently supplies fixed-line broadband and voice services to residential customers. 3. Nova has recently purchased Total Consumer Services Limited and its corporate group (trading as MegaTEL). The MegaTEL business continues to operate as a standalone division of Nova, meaning that Nova is now an MVNO. This has prompted us to become engaged in the Commission’s Mobile Market Study and submit at this stage of the Study. 4. We have kept our submission brief and have focussed primarily on the Commission’s preliminary findings on MVNOs and general development of the mobile market (i.e. we have not focussed on the Commission’s other preliminary findings regarding consumer engagement). 5. Nova would be happy to meet with the Commission to further discuss our submission and the position of fringe MVNOs in New Zealand, as well as the regulatory options (as recommended below) that would better ensure an effective wholesale MVNO market can develop in New Zealand.